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efta-efta00096049DOJ Data Set 9Other

To: BOBBI C STERNHEIM

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DOJ Data Set 9
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EFTA 00096049
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3
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4
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From: To: BOBBI C STERNHEIM Cc: Christian Everdell , Laura Menninger Jeff Pagliuca Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Date: Fri, 07 May 2021 21:16:21 +0000 Bobbi, We understand that you're requesting a November 8th date, and that you prefer that date. Separate from your preferences, our question was simply about your scheduling availability in light of the Court's order. Can you please let us know your availability and we will note that accordingly in our submission to the Court? From: BOBBI C STERNHEIM Sent: Friday, May 7, 20214:00 PM To: (US Cc: Christian Everdell Laura Menninger Jeff Pagliuca Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Good afternoon- For the reasons stated in our letter-motion of 4/22 (Dkt. 246), our earliest and preferred date in the fall is 11/8. In light of Ms. Maxwell's extended period of detention and its deleterious effect on her health and well-being, we cannot agree to a date far bey

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EFTA Disclosure
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From: To: BOBBI C STERNHEIM Cc: Christian Everdell , Laura Menninger Jeff Pagliuca Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Date: Fri, 07 May 2021 21:16:21 +0000 Bobbi, We understand that you're requesting a November 8th date, and that you prefer that date. Separate from your preferences, our question was simply about your scheduling availability in light of the Court's order. Can you please let us know your availability and we will note that accordingly in our submission to the Court? From: BOBBI C STERNHEIM Sent: Friday, May 7, 20214:00 PM To: (US Cc: Christian Everdell Laura Menninger Jeff Pagliuca Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Good afternoon- For the reasons stated in our letter-motion of 4/22 (Dkt. 246), our earliest and preferred date in the fall is 11/8. In light of Ms. Maxwell's extended period of detention and its deleterious effect on her health and well-being, we cannot agree to a date far beyond 11/8. However, should you agree to her release pending trial, we would have greater date flexibility. Enjoy the weekend. Bobbi BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim • •Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. Please use email or fax, instead of regular mail, for all correspondence during this time. We continue to work regular business hours throughout this situation. EFTA00096049 Thank you for your consideration. Our best wishes for your good health and well being. This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. On May 7, 2021, at 1:13 PM Hi Bobbi, wrote: Thanks for your response. Your April 22, 2021 letter does not address the defense's availability for trial dates after November 8th, and it would be helpful to get a complete picture of available dates throughout the balance of 2021 in order to provide the Court with comprehensive information. We're still in the process of conferring with witnesses regarding their availability, so we're gathering a variety of data points. Please let us know your availability and we can put together a proposal. Thanks, From: BOBBI C STERNHEIM Sent: Thursday, May 6, 2021 11:58 PM To: (U Cc: Christian Everdell Laura Menninger ; Jeff Pagliuca Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Good evening- Our 4/22 letter detailed our position. Please let us know your availability for 11/8. Thank you- Bobbi BOBBI C. STERNHEIM, ESQ. EFTA00096050 This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. On May 6, 2021, at 7:15 PM Counsel, wrote: We write to confer in accordance with the Court's Order about a trial date in this case. Please let us know your preferences and availability for trial dates from September 2021 through the end of the year. If you could please provide details for any conflicts, that would be helpful. Thank you, EFTA00096051

Related Documents (6)

DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA STIPULATION GHISLAINE MAXWELL, Defendant. x S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams. United States Attorney for the Southern District of New York, and and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The document marked 3506-001 is a true and accurate copy of a transcript of the deposition taken on November 6, 2009 in West Palm Beach, Florida. EFTA00099019 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1006 may be received in evidence at trial. Dated: November 2021 New York, New York DAMIAN WILLIAMS United States Attorney for the Southern District of New York By: Ass

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA STIPULATION GHISLAINE MAXWELL, Defendant. x S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The document marked 3504-009 is a true and accurate copy of the transcript of a sworn statement taken on November 21, 2005 in West Palm Beach, Florida. EFTA00090929 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1005, and the document marked 3504-009, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under

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DOJ Data Set 9OtherUnknown

From: BOBBI C STERNHEI

From: BOBBI C STERNHEI To: Cc• , Jeff Pagliuca Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Date: Fri, 07 May 2021 21:26:15 +0000 Laura Menninger USANYS We are available to begin November 8th and to conclude by the end of the year. Laura has a civil trial scheduled for December 13th, but will try to move it. Bobbi BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Stemheim "Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. Please use entail or fax, instead of regular mail, for all correspondence during this time. We continue to work regular business hours throughout this situation. Thank you for your consideration. Our best wishes for your good health and well being. This message and any attached documents contain information from the Law Offices of Bobbi C. Stemheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this info

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Court UnsealedLegal FilingUnknown

Court Filing: 123

Ghislaine Maxwell's defense team filed a motion to dismiss Counts One through Four of the superseding indictment for lack of specificity. The motion was filed on January 25, 2021, in the United States District Court for the Southern District of New York. The defense team is represented by multiple attorneys from different law firms.

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Court UnsealedLegal FilingUnknown

Court Filing: 121

Ghislaine Maxwell's defense team filed a motion to dismiss either Count One or Count Three of the superseding indictment, arguing that they are multiplicitous. The motion was filed on January 25, 2021, in the United States District Court for the Southern District of New York. The defense team is represented by multiple attorneys from different law firms.

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DOJ Data Set 9OtherUnknown

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 25, 2020 BY EMAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: We write to disclose the attached notes and 302s, which are stam d SDNY_GM_00332929 through SDNY_GM_00332942, from interviews of Please note that the Government is designating the contents of this letter and its enclosures as "Confidential" under the Protective Order in this case. Very truly yours, AUDREY STRAUSS Acting United States Attorney by: s/ Assistant United States Attorneys (212

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